HALSEY v. PFEIFFER, 2:09-cv-01138

Halsey alleged unconstitutional charges, arrest, prosecution and conviction for the sexual assault and murder of his girlfriend’s children in Plainfield, NJ.
Crimes charged/convicted included two counts each of first-degree murder, felony murder, aggravated sexual assault, possession of a weapon to use unlawfully, and two counts of fourth degree child abuse; trial ended March 18, 1988 with conviction on most counts; he served 21 years.
DNA testing in 2006 showed Halsey was not the perpetrator and pointed to Clifton Hall as the likely offender.
Plaintiff asserted §1983 claims for fabrication/concealment of evidence, coercion, and malicious prosecution, plus supervisory failures and unconstitutional policies; he also asserted state-law malicious prosecution and NJ Civil Rights Act claims.
Defendants Pfeiffer, Lynch, Propsner, and Plainfield moved for summary judgment; the court granted the motions, resolving qualified-immunity issues in defendants’ favor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Coercion of third statement	Halsey asserts Pfeiffer and Lynch coercively obtained the Third Statement.	Pfeiffer and Lynch did not coerce; Miranda rights were read and statement was voluntary.	Qualified immunity; no coercion shown.
Malicious prosecution	Prosecution proceeded without probable cause due to fabricated evidence.	Prosecutor independently decided to prosecute; probable cause supported by multiple sources; no causative fabrication impact.	Qualified immunity; no constitutional violation established.
Brady violation	Failure to disclose exculpatory evidence violated Brady.	Exculpatory info was within Plaintiff’s own knowledge; no Brady violation.	Qualified immunity; no clearly established Brady violation.
Fabrication of evidence claim	Third Statement fabrication violated due process.	No independently actionable Fourteenth Amendment fabrication claim; fabrication tied to Fourth Amendment theory in this context.	Qualified immunity; no independent due process right violated.
State-law claims vs immunities	State-law claims survive the federal qualified-immunity bar.	Good faith immunity applies to state-law claims as well.	Good Faith Immunity applies; dismissal of claims.

Saucier v. Katz, 533 U.S. 194 (Sup. Ct. 2001) (two-step qualified immunity framework (pre-Saucier/clarification lines in this document))
Miller v. Fenton, 796 F.2d 598 (3d Cir. 1986) (totality-of-circumstances test for voluntariness of a confession)
Haynes v. Washington, 373 U.S. 503 (Sup. Ct. 1963) (psychological interrogation tactics permissible if voluntary decision remains autonomous)
Devenpeck v. Alford, 543 U.S. 146 (Sup. Ct. 2004) (probable cause standards and prosecutorial decisions)
Maryland v. Pringle, 540 U.S. 366 (Sup. Ct. 2003) (probable cause requires reasonable belief, not certainty)
Adams v. Williams, 407 U.S. 143 (Sup. Ct. 1972) (probable cause standards for arrest without warrant)
Beck v. Ohio, 379 U.S. 89 (Sup. Ct. 1964) (probable cause standard at moment of arrest)
Wilson v. Russo, 212 F.3d 781 (3d Cir. 2000) (probable cause and prosecutorial decisions in Fourth Amendment context)
Donahue v. Gavin, 280 F.3d 371 (3d Cir. 2002) (malicious prosecution elements and Fourth Amendment linkage)
Rose v. Bartle, 871 F.2d 331 (3d Cir. 1989) (elements of malicious prosecution)
Dansker, 565 F.2d 1262 (3d Cir. 1977) (Brady material within defendant’s knowledge non-disclosable under Brady)
Martinez (GOVERNMENT OF VIRGIN ISLANDS v. Martinez), 831 F.2d 46 (3d Cir. 1987) (Brady applicability and non-disclosure standards)
Yarris v. County of Delaware, 456 F.3d 129 (3d Cir. 2006) (fabrication of evidence context under Fourth Amendment; extent of standalone fabrication claim)